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Feeley & Driscoll's OIG Update: June 2010 The Department of Health and Human Services Office of the Inspector General (HHS-OIG) was established by Congress in 1976 to identify and eliminate fraud, abuse, and waste in HHS programs and to promote efficiency and economy in departmental operations. The OIG is responsible for conducting audits, evaluations, and both criminal and civil investigations for all HHS agencies. These functions are performed by the OIG's Office of Audit Services (OAS). Feeley & Driscoll's OIG Update is a compilation of the latest and greatest additions from the OIG's website, listed in approximate order of greatness rather than lateness. This update is a monthly publication from the Healthcare Group at Feeley & Driscoll, P.C.
Review of New York State’s Compliance With the Political Subdivision Requirement for the Increased Federal Medical Assistance Percentage Under the American Recovery and Reinvestment Act of 2009New York State complied with the political subdivision requirement for receiving the increased Federal medical assistance percentage (FMAP) under the American Recovery and Reinvestment Act of 2009 (Recovery Act). Specifically, the State did not require its social services districts (i.e., political subdivisions) to contribute a greater percentage of the non-Federal share of Medicaid expenditures than the percentage required under the State Medicaid plan on September 30, 2008. For the recession adjustment period (October 1, 2008, through December 31, 2010), the Recovery Act will provide an estimated $87 billion in additional Medicaid funding based on temporary increases in States’ FMAPs. A State is not eligible for the increased FMAP if it requires its political subdivisions to pay a greater percentage of the non-Federal share of Medicaid expenditures than the percentage required under the State Medicaid plan on September 30, 2008. > Click here to view the full report
Under the American Recovery and Reinvestment Act of 2009 (Recovery Act), the Health Resources and Services Administration (HRSA) received $2 billion to expand the Health Center Program to serve more patients, stimulate new jobs, and meet the significant increase in demand for primary health care services among the Nation's uninsured and underserved populations. The OIG’s assessment of Generations Family Health Center, Inc. (Generations), a recipient of HRSA Recovery Act grants, found that Generations is currently financially viable. The OIG found that Generations' financial management system was able to adequately manage and account for Federal funds except that Generations did not have adequate policies and procedures to (1) ensure that it maintained all Federal funds in insured accounts and (2) protect whistleblowers from punishment and discrimination. The OIG recommended that HRSA consider the information presented in this report in assessing Generations' capability as a recipient of HRSA funds. > Click here to view the full report 2009 H1N1 School-Located Vaccination Program ImplementationThe OIG found that the majority of selected localities reported School-Located Vaccination (SLV) to be a useful method to vaccinate a large number of children in a short period of time, and localities reported challenges and lessons learned for future SLV programs. SLV is any vaccination program that takes place on school grounds. Schools provide a convenient location with large spaces such as gymnasiums and cafeterias to host the event. Schools also generally have well-established relationships with community members. SLV can occur before, during, and/or after school hours and involves collaboration between public health departments, schools, and/or school districts. SLV programs may last a month or more within a State or locality, but vaccination at individual SLV sites is typically held for 1 day only. CDC considers SLV to be a viable, large-scale vaccination method for children but indicated in meetings with OIG in late summer 2009 that onsite evaluations of the administration of H1N1 vaccine at SLV sites would be useful because data about local implementation of SLV programs have been limited, especially during influenza pandemics. The OIG found that, by locality, selected SLV sites vaccinated an average of 28 percent of enrolled students during their 1-day programs, ranging from 14 percent to 45 percent. This compares favorably to relevant State and national vaccination rates obtained over a longer period of time and through a variety of methods. For example, the average vaccination rate in the six corresponding States was 37 percent. However, this statewide percentage reflects the number of children vaccinated over a period of approximately 3 months using multiple methods (e.g., private providers, commercial pharmacies, SLV) and for a wider age range. The OIG also found a number of challenges associated with implementing SLV programs. For example, OIG observed the majority of selected SLV sites used recommended vaccine storage containers but did not monitor and record vaccine storage temperature. All selected localities reported challenges securing sufficient SLV staff and distributing them effectively across staffing functions. Additionally, selected SLV sites reported experiencing challenges communicating a clear and consistent message to parents about potential vaccination adverse reactions and the need for a second vaccine dose. Finally, the majority of selected localities had not established a billing system to bill third-party payers for the cost of H1N1 vaccine administration. The selected localities reported a number of things they would do differently in future SLV programs. These include simplifying the consent form and educational materials; standardizing the consent form review process; devoting more staff to registration, triage, and translation; streamlining staff communication and training; developing a centralized information-sharing system; and distributing information to parents and participating schools earlier. The OIG’s data indicate that SLV can be a viable strategy for vaccinating a large number of students in a short period of time. However, SLV programs require a significant amount of planning and resources. To help mitigate challenges in future SLV programs, SLV planners will need specific, timely guidance and sufficient lead time for planning. This report is being issued directly in final form because it contains no recommendations. > Click here to view the full report Review of Medicare Part B Bad Debts at Erlanger Medical Center for the Fiscal Year Ended June 30, 2005For fiscal year 2005, Erlanger Medical Center claimed on its Medicare cost report bad debts totaling $49,000 ($35,000 reimbursement) that were not allowable under Medicare regulations. > Click here to view the full report Review of Medicare Part A Bad Debts at Erlanger Medical Center for the Fiscal Year Ended June 30, 2005For fiscal year 2005, Erlanger Medical Center claimed on its Medicare cost report bad debts totaling $55,000 ($38,000 reimbursement) that were not allowable under Medicare regulations. > Click here to view the full report Excluded Medicaid Providers: Analysis of EnrollmentIn their review of excluded Medicaid providers and the States that enrolled them, OIG found that States impose few enrollment requirements beyond those mandated by Federal regulations. Over half of the excluded providers were subject to no State enrollment requirements beyond the Federal regulations when they enrolled in Medicaid. Pursuant to Federal regulations at 42 CFR § 455.104 and 42 CFR § 455.106, States require providers to disclose information on ownership and control of an entity and criminal convictions related to Federal health care programs. However, the regulations do not require States to verify this information. The OIG reviewed the criminal and financial backgrounds of a group of 188 Medicaid providers from 26 States that the Office of Inspector General excluded between January 1, 2007, and June 30, 2008. The OIG examined the providers' backgrounds before and after they enrolled to gather information related to potential weaknesses in States' provider enrollment procedures. In addition, the OIG surveyed the 26 States that enrolled the 188 providers about the procedures they used to enroll the providers and the process they currently use to enroll providers. Eight out of the 188 excluded providers disclosed false ownership information at the time of enrollment. Another eight out of 188 had criminal convictions before they enrolled and committed health care-related crimes after they enrolled. Forty-eight of the 188 excluded providers had Federal or State tax liens before or after they enrolled in Medicaid. Twenty-four out of 188 excluded providers had a history of tax debt, criminal convictions, or false disclosures before they enrolled. CMS agreed with their results. > Click here to view the full report Performance Data for the Senior Medicare Patrol Projects: May 2010 Performance ReportThe Senior Medicare Patrol Projects receive grants from AoA to recruit retired professionals to serve as educators and resources in helping beneficiaries to detect and report fraud, waste, and abuse in the Medicare program. At least 1 project is located in each of the 50 States, as well as in the District of Columbia, Puerto Rico, Guam, and the Virgin Islands. In 2009, the 55 projects had a total of 4,444 active volunteers. These volunteers’ educated beneficiaries in 7,177 group education sessions and held 33,855 one-on-one counseling sessions. In addition, the projects conducted 311,377 media outreach activities and 5,684 community outreach education events. Medicare funds recovered attributable to the projects were $76,176 and total savings to Medicare, Medicaid, beneficiaries, and others were $214,060. The projects had 5 percent fewer active volunteers in 2009, compared to the number in 2008. Despite this fact, total savings to Medicare, Medicaid, beneficiaries, and others were over three times higher in 2009, compared to totals in 2008. In December 2005, AoA requested that OIG continue to collect and report performance data for the Senior Medicare Patrol Projects to support AoA's efforts to evaluate and improve the performance of these projects. OIG agreed to collect performance data every 6 months but to report the data on an annual basis. The OIG continue to emphasize that the number of beneficiaries who have learned from the Senior Medicare Patrol Projects to detect fraud, waste, and abuse, and who subsequently call the OIG fraud hotline or other contacts, cannot be tracked. Therefore, the projects may not be receiving full credit for savings attributable to their work. In addition, the projects are unable to track substantial savings derived from a sentinel effect whereby fraud and errors are reduced in light of Medicare beneficiaries' scrutiny of their bills. > Click here to view the full report Results of Limited Scope Review of Loudoun Community Health CenterThe OIG reviewed the financial condition of Loudoun Community Health Center, located in Virginia, as part of a nationwide series of reviews of community health centers that have received funding under the American Recovery Act of 2009 (Recovery Act). Based on their assessment, OIG believes Loudoun Community Health Center is financially viable and has the capacity to manage and account for Federal funds and to operate its health center in accordance with Federal regulations. However, the OIG noted certain weaknesses related to the accounting system, segregation of duties, procurement practices, adequate safeguarding of assets, and a whistleblower process. When monitoring the Recovery Act funds, the OIG recommends that HRSA consider the information presented in this report in assessing Loudoun's ability to account for and manage Federal funds and to operate a community health center in accordance with Federal regulations. In written comments on the OIG’s draft report, Loudoun Community Health Center provided information on actions that it had taken to address the findings. > Click here to view the full report Review of the Department of Health & Human Services’ Limited Data-Quality Reviews of Information Reported by Recipients of Recovery Act FundsSection 1512 of the American Recovery and Reinvestment Act of 2009 (Recovery Act) requires recipients of certain Recovery Act funds to report to the applicable Federal agency, not later than 10 days after the end of each calendar quarter, (1) the total amount of Recovery Act funds received and the amount that was expended or obligated, (2) a detailed list of all projects for which Recovery Act funds were expended or obligated, and (3) detailed information on payments to sub recipients and vendors. Federal agencies are required to conduct limited data-quality reviews intended to identify material omissions and/or significant errors in the recipients’ reported information. For the first and second reporting periods (February 17 through September 30, 2009, and October 1 through December 31, 2009), the OIG found that the Department’s limited data-quality reviews of recipient-reported Recovery Act information identified material omissions and significant errors, and the Department took several steps to minimize material omissions and significant errors. Consequently, this report contains no recommendations. > Click here to view the full report |
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